EAC’s New Quorum Publishes VVSG 2.0 for Public Comment

The election community’s long(!) wait for a fully-constituted EAC paid off yesterday with the announcement that the full Commission has unanimously voted to release Version 2.0 of the Voluntary Voting System Guidelines for public comment. Here’s the EAC release:

Today, the U.S. Election Assistance Commission’s (EAC) four sitting Commissioners unanimously voted to publish the proposed Voluntary Voting System Guidelines 2.0 (VVSG) Principles and Guidelines in the Federal Register for a 90 day public comment period, after which comments and feedback on the proposed document will be compiled and presented to the Commissioners for discussion and consideration.

“Today’s unanimous vote demonstrates the Commissioners’ shared commitment to taking this next important step in consideration of the proposed VVSG 2.0 Principles and Guidelines. The EAC looks forward to holding hearings on these Principles and Guidelines soon and we encourage the public to provide their feedback on the proposed guidelines,” said EAC Chairman Thomas Hicks, who joined Vice Chair Christy McCormick, Commissioner Ben Hovland and Commissioner Donald Palmer in supporting the measure.

According to today’s vote, the proposed VVSG 2.0 Principles and Guidelines will be published in the Federal Register in accordance with sections 222(a)(1) and 222(d) of the Help America Vote Act of 2002. They will appear in the Federal Register for a period of 90 days. Separately, upon the completion of the VVSG 2.0’s accompanying Requirements developed by NIST and the EAC, those accompanying Requirements will also be subject to public review and comment, including distribution to the EAC’s Technical Guidelines Development Committee (TGDC), Standards Board and Board of Advisors. This review and comment period will take place prior to consideration and implementation by the Commission.

VVSG are a set of Principles, Guidelines and Requirements against which voting systems can be tested to determine if the systems meet required standards. Some factors examined under these tests include functionality, accessibility, accuracy, auditability and security capabilities. The Help America Vote Act of 2002 mandates that EAC develop and maintain these requirements as well as testing and certifying voting systems. On December 13, 2005, the EAC unanimously adopted the 2005 VVSG, which significantly increased security requirements for voting systems and expanded access, including opportunities for individuals with disabilities to vote privately and independently. The 2005 guidelines updated and augmented the 2002 Voting System Standards, as required by HAVA, to address advancements in election practices and computer technologies. These guidelines were again updated by the EAC’s Commissioners on March 31, 2015. These guidelines are voluntary. States may decide to adopt them entirely or in part prior to the effective date.

The structure of the new VVSG reflects modifications proposed by the election community, EAC, NIST and the TGDC, which is comprised of election officials, voting system manufacturers, disability experts, cyber security experts, technology experts, and other key election stakeholders. The new guidelines are a high level set of principles that will be supplemented by accompanying documents that detail specific requirements for how systems can meet the new guidelines and obtain certification. The supplemental documents will also detail assertions for how the accredited test laboratories will validate that a system complies with those requirements.

Last Spring, the EAC convened its advisory boards to review and comment on the adoption of the newest version of the voluntary guidelines, VVSG 2.0. Both Boards recommended that the EAC adopt VVSG 2.0. Today’s unanimous Commissioner vote occurred less than two weeks after a quorum of Commissioners was restored at the EAC.

This vote is a welcome sign that the EAC is back to business very shortly after being restored to full strength. VVSG 2.0 is intended to help election officials, manufacturers and the entire community with a mechanism for testing and certification of voting equipment as well as a set of principles to guide development and assessment of future iterations of election technology. [Here’s my post from 2017 with a high-level summary of the principles. I look forward to the results of public comment and eventual formal adoption of VVSG 2.0. Stay tuned …

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